Likely not with ATBs. Whether it's your brake caliper, or a bit of grip on the ground, that's stopping a wheel from freely wheelspinning - you typically never get full engine torque directed to the other half shaft.
The above is another rarely mentioned positive in favour of ATBs, no real need to upgrade the rest of the driveline to HD. In contrast, the common wisdom around fitting a locker is you should upgrade ALL your driveline to HD components.
That said: you can break a half shaft (or cv etc) easily with any kind of diff just being silly. eg: when a wheel is off the ground and wildly spinning - then touches down hard with power still on...



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